This policy is applicable to the Processing of customers’ Personal Data at all companies included in the Spowdi Group (“Spowdi”, “our”, “us” or “we”). The purpose of this policy is to provide our current, former and potential customers (jointly referred to as “customers” or “you”) with a general understanding of:
- The circumstances under which we collect and process your Personal Data
- The types of Personal Data we collect
- The reasons for collecting your Personal Data
- How we handle your Personal Data
- Distribution of responsibility for the Processing of Personal Data between various legal entities at Spowdi, and
- Contact details for us so you can receive information about and claim your rights in relation to our processing of your Personal Data.
This policy is updated continuously to reflect the measures taken by Spowdi in relation to your Personal Data.
Spowdi AB (a Swedish legal entity with corporate registration number 559098-2954) is the Controller in relation to Processing of your Personal Data.
Spowdi contractually requires its dealers and repairers to comply with rules concerning data protection. Note that Spowdi and its authorised dealers and repairers are separate legal entities, and that we are generally not responsible if such dealers and repairers do not follow applicable laws. If you have questions regarding your dealer’s or repairer’s use of your Personal Data, please contact the dealer or repairer directly.
What we use your personal data for
When you use or interact with Spowdi, we use a variety of technologies to process the personal data we collect about you for various reasons. Personal data are used for these purposes:
- To evaluate and develop new features, technologies, and improvements to Spowdi products.
- To provide and personalize the website.
- For marketing, promotion, and advertising purposes.
- To comply with legal obligations and law enforcement requests.
- To establish, exercise, or defend legal claims.
- To conduct business planning, reporting, and forecasting.
- To process your payment.
- To conduct research and surveys.
Principles of data process
The Processing of your Personal data forms an important part of our provision of products and services to you. We appreciate the trust you place in us when providing us with your Personal data and consider your privacy an essential part of the services we offer. In order to safeguard your Personal Data while increasing the customer value and offering enhanced and safer user experiences, we adhere to the following five general principles.
Freedom of choice
Your Personal Data belongs to you. We strive not to make any assumptions regarding your privacy preferences and aim to design our services so that you can choose whether or not to share your Personal Data with us.
Balance of interest
Where the Processing of your Personal Data is required by law or necessary for the pursuit of a legitimate interest, and where this interest outweighs the need to protect your privacy, we may process certain Personal Data.
Spowdi will only process our customers’ Personal Data if it is adequate, relevant and necessary in relation to the purpose for which it has been gathered. We aim to anonymize your Personal Data when a function or service can be achieved with anonymized data. If we combine anonymized or non-Personal Data with your Personal Data, it will be treated as Personal Data for as long as it remains combined.
Transparency and security
Spowdi believes in being transparent about which Personal Data we process and for which purposes. To us it is also vital to protect your Personal Data since one of Spowdi’s core values is to protect what is important to you. On request, Spowdi will provide customers with further information regarding our Processing and protection of your Personal Data.
It is Spowdi’s policy to comply with the applicable laws, rules and regulations governing privacy and data protection in each and every country where we operate. Where necessary, we will adjust our Processing of your Personal Data as described in this policy to ensure legal compliance.
The Personal Data which Spowdi collects about you and the water distribution system will be used:
- to provide you with products and services, including to verify your eligibility for certain purchases and services as well as to offer you enhanced offers and experiences;
- to inform you of updates to, or changes in, our products and services, including but not limited to changes to our terms and conditions and policies;
- to inform you of new products, services and events;
- to provide product support and services (warranty service, recall information, etc.);
- for product development purposes, for example to improve water distribution system performance, quality and safety;
- to evaluate and improve our offering to, and communication with customers;
- to comply with legal requirements or lawful authority requests;
- to inform you about our products and services and identify those that may be of interest to you;
- to carry out market research; and
- or analysis and customer profiling purposes (online and social included) done by ourselves and our chosen suppliers.
Spowdi makes use of the below listed definitions in this policy:
- “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data;
- “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
- “Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- “Sensitive Personal Data” means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the Processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
You may provide us with information about you or your water distribution system when utilising Spowdi’s services in or outside contacts with Spowdi, for example through our websites or dealers. We may also obtain such data from our authorised dealers and repairers and other third parties. Such data may include:
- your contact information (name, address, telephone number, email address, etc.);
- water distribution system information (identification number, model, date of purchase, service history, etc.);
- location data generated by your activities (search queries, location sharing, etc.); and
- data pertaining to your purchase and use of our products and services (customer preferences and settings, purchase history, etc.).
Where reasonably practical or as required by applicable law, we will, in connection to collecting or registering your Personal data, provide you with (i) specific information as to the purposes of the Processing of your Personal Data, (ii) the identity of the Controller, (iii) the identities of any third parties to whom the data may be disclosed and (iv) other information which may be necessary to ensure that you are able to safeguard your rights. The above information may, for example, be provided when you purchase a water distribution system, in mobile applications developed by Spowdi, or otherwise in an agreement which you enter into with Spowdi.
For most Processing acts, you are able to terminate our use of your Personal Data by updating your preferences or terminating a particular service by contacting Spowdi at the address indicated in the “Information and access” section below or as otherwise instructed by us. However, and unless otherwise follows from applicable law, you may generally not opt out of the Processing of your Personal Data:
- which we perform in order to send you important notices, such as changes to our terms and conditions and policies or in case of product recalls; and
- which we perform in order to comply with our legal obligations.
We will only retain your Personal Data for as long as it is necessary to fulfil the purposes outlined in this policy or the purposes of which you have otherwise been informed. This means that we will retain the data for as long as the customer relationship lasts (and, where applicable, until the expiry of the warranty period) or until you withdraw your choose to erase your personal data.
When we process your Personal Data, we strive to ensure that it is correct and up to date. We attempt to delete or correct Personal Data that is incorrect or incomplete. For more information regarding your right to ensure the accuracy of your Personal Data held by us, please see the “Information and access” section below.
Information and access
As stated in the “Notice” section above, we may provide you with specific information concerning our Processing of your Personal Data when collecting or registering such data. You have the right to request (i) a copy of the Personal Data that we store about you, (ii) that we correct or remove Personal Data that you think is inaccurate, and (iii) to have your Personal Data deleted and to have our processing of your Personal Data restricted in certain circumstances. In addition you have the right to object to our processing of your Personal Data as well as to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format and to have these transmitted to another Controller.
Requests should be sent to the legal entity stipulated in the end of this document. Your requests will be dealt with in a prompt and proper manner.
Spowdi has taken technical and organisational measures in order to protect your Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of Processing.
Disclosures to third parties
Spowdi may share your Personal Data:
- among Spowdi units;
- with Spowdi authorised dealers and repairers, for the purpose of distributing product and service offers and other communications to you; with other business partners for the purpose of distributing product and service offers and other communications to you or for research and development purposes;
- in connection with the sale or transfer of a Spowdi entity or its assets;
- as required by law, for example in connection with a government inquiry, dispute or other legal process or request;
- when we, in good faith, believe that disclosure is necessary in order to protect our rights, for example in order to investigate potential violations of our terms and conditions or to detect, prevent or disclose fraud or other security issues.
- when disclosure is required by law; and
- when disclosure is necessary for the purpose of a legitimate interest pursued by Spowdi (for example in order to protect our legal rights, as described above).
Data processing on our behalf
We restrict access to your Personal Data to Spowdi’s employees and suppliers who need to use the information in order to process it on our behalf, and who are contractually required to keep your Personal Data secure and confidential. We aim to choose the option for Processing services that best safeguards the integrity of your Personal Data towards any third party. Some of these processing activities might be performed outside of the EEA under a specific legal basis as required by national law.
We will not sell or trade your Personal Data with third parties. We may provide you with information regarding new products, services, events or similar marketing activities. If you wish to unsubscribe to a particular e-mail newsletter or similar communication, please follow the instructions in the relevant communication.
Websites and cookies
When you download or register to use one of our apps, you may submit Personal Data to us such as your name, email address, phone number and other registration information. Further, when you use our apps, we may collect certain information automatically, including technical information related to your mobile device, and information about the way you use the app. Depending on the particular app you use we may also collect information stored on your device, including contact information, location information or other digital content. Further details about the kind of information we collect is set out in the information notice and/or the special notice for each individual app.
Our services and products are not intended for use by children. We do not knowingly solicit or collect any Personal Data about children under the age of 13 nor market our products or services to them. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 13, please contact us. If we learn that we have inadvertently collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
To exercise your rights as a data subject, e.g. to obtain information or access to Personal Data that Spowdi process, kindly send an e-mail to privacy[at]spowdi.com.