Family Hub Privacy Notice

 

Effective Date: 25/05/2018

 

Samsung Electronics UK Limited (“Samsung” or “We”) and its affiliated companies respect your concerns about privacy.  This Privacy Notice applies to the personal information we collect through the Family Hub service (the “Service”).  It does not apply to information collected by other apps, websites or services provided by Samsung or its affiliated entities.

 

Family Hub is a Smart fridge with a touch screen with various applications. Its features include Food management, Family Connection, Entertainment.

 

To use Family Hub, you must first have a Samsung Account. Our Privacy Policy at https://account.samsung.com/membership/pp (“Samsung Privacy Policy”) will apply to your use of your Samsung Account and Family Hub. This Privacy Notice provides further information about how your personal data is used in connection with Family Hub, and should be read in conjunction with the Samsung Privacy Policy.

 

In this Privacy Notice, we describe the types of information collected through Family Hub, how we may use the information, how long we may keep the information, with whom we may share it and the choices available to you regarding our use of the information and exercising your rights.  We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices. Samsung is the data controller for the processing of personal data.

 

Information We Obtain

 

Through Family Hub, we obtain information about you in various ways.  The types of personal information we obtain include:

 

 

 

·         Samsung Account Information.  We collect information associated with your Samsung Account used to access Family Hub, such as your name, email address and Samsung Account ID.

 

·         Family Hub Interactions.  We collect information you exchange with Family Hub through your interactions with the Service, including recordings of your voice commands (such as your questions, requests and instructions), your pictures, your touch interactions and other inputs, your country, information you have created or input in the Family hub including a name of group that you have created to share your memo or picture with the group members, and the information you receive from the Service (such as responses, answers and content). If you submit information to Family Hub that is sensitive in nature (i.e., health information), that will also be collected and processed for the purposes set out below. We will not actively collect such information without first obtaining your separate explicit consent, or as provided for by applicable law. We also may obtain other information related to your use of Family Hub, including the information (such as information related to the apps you use, the websites you visit and your contact lists, pictures, music, calendar entries, bookmarks, notes, alarm clock, and content and data from other Samsung and third-party apps, websites and services) we receive from Samsung and third-party apps and services that are accessed or used by Family Hub to provide you with the Service (such as social media, email and instant messaging apps).

 

 

·         Device and App usage Information.  We collect information through automated means about your use of Family Hub, and this may include device models, OS versions, device configurations and settings, IP addresses, and device identifiers and other unique identifiers.  In addition, we may obtain information about how, when and for how long you use your Family Hub, including your usage of Samsung and third-party apps (such as a listing of apps on your devices, music played on your devices, the websites you visit and the searches you make).

 

Samsung’s servers may receive information when you interact with Family Hub, such as information about your use of Family Hub, your interactions with Family Hub, your geolocation and the devices you use to access Family Hub.

 

How We Use the Information We Obtain

We use the information we obtain through the Service to:

 

·         provide you with the Service, such as to respond to your requests, questions and instructions made through Family Hub;

·         identify and authenticate you so you may use certain Service;

·         improve and customize your experience with the Service, such as delivering content and responses tailored to our users and the manner in which they interact with Family Hub;

·         with your separate consent, communicate with you about our products and services, and provide you with notifications, content, alerts, offers, promotions, marketing information, communications and advertisements;

·         respond to your requests and inquiries;

·         operate, evaluate and improve our business (including developing new products; enhancing and improving our products and the services; managing our communications; analyzing our products, customer base and the services; conducting market research; performing data analytics; and performing accounting, auditing and other internal functions);

·         allow you to interact with and use certain third-party apps and services;

·         protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and

·         comply with and enforce applicable legal requirements, relevant industry standards and our policies, including this Privacy Notice, the Samsung Account Privacy Policy.

 

Through Family Hub, we may collect personal information about your online activities over time and across third-party apps, websites and other online services.  We may use third-party analytics services on our Service. The providers that administer these analytics services help us analyze your use of the Service and improve our Service.  The information we obtain may be disclosed to or collected directly by these providers and other relevant third parties who use the information, for example, to evaluate use of the Service, help provide the Service, and diagnose technical issues.

 

Samsung processes personal data for the purposes described above.  Samsung’s legal basis to process personal data includes processing that is: necessary for the performance of the contract between you and Samsung (for example, to provide you with the Service and to identify and authenticate you so you may use certain Service); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for Samsung’s legitimate interests (for example, to manage our relationship with you and to improve the Service); and based on obtaining your separate consent (for example, to communicate with you about our products and services and provide you with marketing information), which may subsequently be withdrawn at any time by contacting us as specified in the How to Contact Us section of this Privacy Notice without affecting the lawfulness of processing based on consent before its withdrawal.   

 

You are required, as a necessity to enter into a contract, to provide us with personal data for processing as described above.  If you do not provide us with personal data, we will not be able to provide you all of the features available through Family Hub.

 

Information Sharing

 

We do not disclose personal information about you through the Service, except as described in this Privacy Notice.  Limited members of the Family Hub service team in Samsung may access and other wise process personal data in connection with their job responsibilities or contractual obligations. We may share your personal information with our subsidiaries and affiliates and with service providers who perform Service for us.  We do not authorize our service providers to use or disclose the information except as necessary to perform Service on our behalf or to comply with legal requirements.

 

Some of these personnel, affiliates and third party service providers are located outside of the EEA, including in countries that may not provide the same level of data protection as the home country of our customers, including, for example and without limitation to the Republic of Korea, the United States of America and Japan. Samsung takes appropriate steps to ensure that such recipients are bound to duties of confidentiality and Samsung implements measures such as standard data protection contractual clauses to ensure that any transferred personal data remains protected and secure.  A copy of these clauses can be obtained by contacting us as specified in the How to Contact Us section of this Privacy Notice.

 

When you use Family Hub to access or interact with third-party apps and services, we may send certain personal information to the providers of such third-party apps and services to provide you with the services you request.  Examples of this information may include the voice commands you make to operate these apps and services, your geolocation and other location data, and other data that helps facilitate the services you request.  These third parties also may collect certain personal information directly from your devices through Family Hub. Samsung is not responsible for these third-party providers’ privacy or security practices.  The privacy and security practices of the relevant providers, including details on the information they receive from us or collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review.

 

Samsung, our subsidiaries and affiliates, and our third-party service providers also may disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; (6) in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, sale, transfer, reorganization, dissolution or liquidation); or (7) otherwise with your separate consent.

 

 

Retention of Personal Data

 

We take appropriate steps to ensure that information about you based on the following logic:

1. at least the duration for which the information is used to provide you with the Service;

2. as required under law, a contract, or with regard to our statutory obligations; or

3. only for as long as is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or for statistical purposes, subject to appropriate safeguards.

 

Your Choices

 

We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, limit the communications you receive from us, or submit a request, please contact us as specified in the How to Contact Us section of this Privacy Notice.  

 

Please visit the Family Hub settings on your device for choices that may be available to you in connection with your use of Family Hub.. Please note that if you decline to allow Family Hub to collect or share certain information, you may not be able to use all of the features available through Family Hub.

 

Your Rights

 

You have the right to request details about the information we collect about you and to request us to correct inaccuracies in that information, to object to or request the restriction of processing, to request access to, the erasure or portability of your information. Under the laws of some jurisdictions, we may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. If you would like to make a request to access your information, please contact us at dataprotection@samsung.com.

If you request deletion of personal information, you acknowledge that you may not be able to access or use the Business Service and that residual personal information may continue to reside in Samsung’s records and archives for some time, in compliance with applicable law, but Samsung will not use that information for commercial purposes. You understand that, despite your request for deletion, Samsung reserves the right to keep your personal information, or a relevant part of it, in line with our data retention policy and applicable laws, if Samsung has suspended, limited, or terminated your access to the website for violating the Samsung Terms of Use, when necessary to protect the rights, property, or safety of Samsung, or any of our respective affiliates, business partners, employees or customers.

 

How We Protect Personal Information

 

We maintain appropriate administrative, technical and physical safeguards designed to protect personal information we obtain through the Service against accidental, unlawful or unauthorized destruction, interference, loss, alteration, access, disclosure or use.  Samsung also maintains reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current.

 

Updates to Our Privacy Notice

 

This Privacy Notice may be updated periodically to reflect changes in our personal information practices with respect to the Service, or changes in the applicable law.  We will post a notice on our website and/or your device to notify you in advance of material changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated.

 

How to Contact Us

 

If you have any specific questions, please contact us (EU Data Controller) at:

European Data Protection Officer

Samsung Electronics (UK) Limited

Samsung House, 1000 Hillswood Drive, Chertsey, Surrey KT16 0PS

You can also contact us at dataprotection@samsung.com or http://www.samsung.com/uk/info/privacy/

 

 

Your Right to File a Complaint

You may lodge a complaint with a supervisory authority by accessing and contacting the following URL (https://ico.org.uk) if you consider that our processing of your personal data infringes applicable law.