Introduction to data protection at BSH
1. About us and our website
We, BSH Home Appliances Pty Ltd (BSH) of 1555 Centre Road, Clayton, Victoria, 3168, operate this website. Please use the contact information provided below to contact us.
2. Our guiding principles
BSH is committed to protecting your personal information. Your data is therefore processed with great care and in strict compliance with applicable data protection law.
BSH must comply with the Privacy Act 1988 (Cth) (Privacy Act), and handles the personal information that it collects in accordance with the Australian Privacy Principles contained in the Privacy Act. BSH is also required to comply with the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).
Organizational and technical security measures have been taken to protect all of our websites against the risks present in processing personal data. Our partners who support us in the provision of this website must comply with these provisions as well.
Personal information
1. What is personal information?
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether that information is true or not and whether it is recorded in a material form or not.
2. How does BSH collect your personal information?
BSH collects the personal information from you when you:
- purchase our products or services or receive a refund;
- complete a warranty registration or make a warranty claim;
- respond to one of our surveys, promotions or competitions;
- otherwise contact us, either online through our website, our social media accounts via direct message, by email, mail, in person or by phone (you will be informed if we record phone calls and why);
- register to receive newsletters or updates from us;
- access and use any of our website services;
- post a consumer or product review or comment about a BSH product or review information about a BSH product on our websites or one of our social media accounts (including Facebook, Youtube and Instagram) or a third party website, such as sites operated by our retailers;
- attend one of our brand experience centres; or
- apply for a job with us.
Sometimes we may also collect your personal information from third parties such as when:
- you return a warranty registration to a third party you bought a BSH product or service from;
- given the nature of the job you have applied for, we require you to take a medical assessment, police check and/or drivers licence check;
- you publically post on or privately send a consumer or product review or comment about a BSH product via a third party website which our third party service providers help us to collect; or
- you visit and access or request information about BSH products and services from our retailer websites.
3. What personal information does BSH collect?
The personal information which BSH may collect about you includes:
- your name and contact or delivery details including address, email address and phone number;
- your credit card and/or banking details;
- details of the product or service you have purchased, including warranty details;
- information which you provide to us in response to one of our surveys, promotions or competitions;
- records of our communications with you, including any complaints, requests, claims, or after-sales service issues or queries;
- details of your attendance at one of our brand experience centres;
- information provided by you and third parties as part of your job application (depending on the role for which you have applied this may include sensitive information and/or government related identifiers);
- information in any consumer or product review or comment you publically post on or privately send via our websites, social media accounts or third party website;
- your visits to and activities on our retailer websites in connection with our products and services; and
- if you apply for a job with BSH, depending on the type of job you apply for, we may also collect additional information such as your criminal record through police checks, and heath information for a functional capacity evaluation.
4. Use of personal information
BSH will use your personal information for the purposes of carrying out our business including:
- delivering a product or service that you have purchased from us;
- customer administration, including for registering and managing warranties, responding to complaints, claims, enquiries, comments and requests, and performing after-sales services and assessing and responding to consumer or product reviews;
- product and service development;
- surveys, promotions, market research and direct marketing;
- assessing your job application;
- technical administration of the BSH websites; and
- complying with our legal obligations.
5. Dealing with us anonymously or using a pseudonym
Where practical and lawful, you can deal with us anonymously or use a pseudonym if you wish including when you post a consumer or product review or comment. However in many instances, if we cannot identify you or if you do not provide us with the personal information we request, then we may not be able to provide you with our products or services, respond to your enquiries, review, comments, posts or complaints, or assess job applications.
6. Direct marketing and opting-out
Depending on how we collect your personal information and interact with you, we may, with your consent where required, communicate with you (e.g. via email, SMS, mail or telephone or via our social media account messaging) about our current and new products and services or promotions. If you do not wish to receive direct marketing communications from us in the future you may opt-out at any time by contacting the Privacy Officer on 03 8551 1100 or via email to bshau-disec@bshg.com
7. Disclosure of personal information
We work together with a number of third parties. We have chosen these service providers carefully to keep your information safe. We may need to disclose to, or share your personal information with third parties, some of which may be located overseas, including:
- to our related companies within the BSH Group (principally located in Singapore, India, China and European Economic Area (EEA) countries);
- to third parties such as our agents, contractors, product distributors and service providers that we engage to provide services such as hosting services, programming services, sales and marketing services and hotline services (including through their online platforms) to us or on our behalf (principally located in the United States of America, Singapore, India and EEA countries);
- to social media sites such as Facebook to create customised audiences for targeted marketing;
- where disclosure is otherwise authorised or required by or under an Australian law or court/tribunal order.
8. Quality and security of personal information
BSH takes reasonable steps to ensure that the personal information it collects is accurate, up-to-date and complete, and when being used or disclosed, relevant for the purpose of the use or disclosure. Please help us to maintain the quality of your personal information by contacting us on the details below if you believe that the personal information which BSH holds about you may be inaccurate, incomplete, out-of-date or irrelevant.
BSH has security measures in place to protect the personal information we hold against misuse, interference and loss, and from unauthorised access, modification or disclosure. In order to keep your information secure, we hold personal information in an electronic format on a central database held on secure servers which are owned and operated by our related companies, principally located in Singapore, India, China and European Economic Area countries. These companies are subject to the BSH Group's corporate guidelines on data protection and information security. Our service providers who may also hold or host on the servers or platforms information we collect through the use of their services are subject to obligations to ensure the security of information they process on our behalf. We also hold some personal information in hard copy. These documents are held in secure locations within BSH offices or archive facilities. BSH restricts access to documents containing personal information to those employees who need it for the purpose of conducting BSH business in accordance with this Privacy Policy.
Our security procedures are continually enhanced as new technology becomes available.
Data processing on the website
1. Website technology and cookie use
When you visit our websites our web servers automatically record the following information:
- date of the access;
- time and length of the access;
- URL of the linking website;
- name of your internet service provider;
- websites you actually visit;
- files accessed;
- browser type and version;
- operating system;
- IP address.
This information is collected via cookies and active components (e.g. JavaScript) which BSH uses to follow the preferences of our visitors and optimize our websites accordingly. BSH does not attempt to identify you using this information. You can reset your browser either to notify you when you receive a cookie, or to refuse to accept cookies. Please note that certain areas of most sites may not function properly if you reject a cookie. Some expire at the end of each session and some remain for longer so that when you return to our website, you will have a better user experience. We use cookies to personalise content we send to you and to make our marketing more relevant.
BSH allows third parties to use, third party cookies on the BSH websites to display relevant ads when you are visiting BSH websites, external websites and social media platforms. Third party cookies may be used by organisations such as, Facebook and Google, amongst others.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit, www.allaboutcookies.org.
In order to help us design our website appropriately, we may collect usage data relating to your visit to our website using analytics cookies and other technologies. As part of this, we record the mouse movements and clicks of randomly selected users of our website. Your IP address is anonymised as a matter of course. The resultant log of your use of our website is randomly analysed so that we can derive potential improvements for our website from it.
We use service provider Mouseflow ApS, Flaesketorvet 68, 1711 Copenhagen, Denmark for the purpose of collecting this usage data.
We do not conflate the resultant usage profiles with your name or any other details that could disclose your identity, such as your e-mail address. Under the Privacy Act, we are permitted to process data in this context with your consent. The usage data is deleted three months after the date on which it is collected.
Opt-out: Please use Mouseflow's opt-out website via the following link if you wish to prevent this usage data being collected: https://mouseflow.com/opt-out.
We use “chat functions” on our websites to answer queries and to provide an additional option for providing support. We use service provider Zendesk Inc. for this purpose and you can find its privacy policy at https://www.zendesk.com/company/customers-partners/privacy-policy/
Our websites may also use other web analytics tools and technologies to facilitate the purchase of our products you wish to buy including by connecting you to products available on our retailers' websites, and to understand your purchasing and other activities on our retailers' websites in connection with our products and services.
The BSH websites may include links to other websites which are not covered by this privacy policy and for which BSH has no responsibility.
2. Newsletter
Our website provides the option of subscribing to our newsletter. If you subscribe to receive our newsletter, and therefore consent to it being sent to you, your details are solely used in order to send you the newsletter. You can withdraw this consent at any time. The relevant link is included in each copy of our newsletter. We will make a note of the fact that you have unsubscribed from the newsletter in our database.
User rights
1. Your right to access, correct and complete your personal information
You may generally access on request personal information which BSH holds about you, and you may request without charge corrections to personal information which you believe is inaccurate, out-of-date, incomplete, irrelevant or misleading. To make a request, please contact our Privacy Officer on the details below.
We may need to ask you a few questions in order to verify your identity before we can respond to your request. If we are unable to provide access to, or correct your personal information, we will inform you in writing of our reasons and how you may take the matter further if you are not satisfied with our decision.
You can also ask us to associate with your information a statement if you believe the information is inaccurate, out-of-date, incomplete, irrelevant or misleading which we will take reasonable steps to do.
2. Your point of contact for questions relating to your personal information
If you have any questions about how BSH handles your personal information, or if you are concerned that we may have breached your privacy and wish to make a complaint, please put your complaint in writing and send it by mail or email to our Privacy Officer using the details below. We will investigate your complaint and will notify you of a decision in relation to your complaint as soon as practicable after it has been made.
If your complaint is not resolved to your satisfaction, you can contact the hotline of the Office of the Australian Information Commissioner (OAIC) on 1300 363 992 to make a query about your privacy rights, or to lodge a complaint about how we have handled your personal information. The OAIC has the power to investigate the matter and make a determination.
Privacy Officer
BSH Home Appliances Pty Ltd
1555 Centre Road Clayton
Victoria, Australia 3168
Email: bshau-disec@bshg.com
Telephone: 03 8551 1100
3. Changes to this policy
BSH reserves the right to update this privacy policy from time to time to reflect changes to our information handling practices or legal obligations. Any changes will be effective from the date that they are posted on this website.
Last updated: 19th November 2020
Pinterest Tag
Our website uses Pinterest Tag, a service provided by Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland, (“Pinterest Europe”).
Pinterest Tag help us analyze use of our website and to track the effectiveness of our advertising campaigns (Conversion Tracking). We also use the Pinterest Tag to create audiences and show you personalized advertising based on your interest in our products (retargeting). For this purpose, Pinterest Europe processes data, which the service collects from pixels, cookies and similar technologies on our website.
If you have a Pinterest account and have allowed Pinterest Europe to do so in your account’s privacy settings, Pinterest Europe may also link the information collected about your visit to us with your Pinterest account and use it for showing you the targeted advertisements. You may see and change the privacy settings, especially for personalization, in your Pinterest account at any time. For more information, please see https://help.pinterest.com/en/article/edit-personalization-settings.
If you have not agreed to the use of the Pinterest Tag, Pinterest Europe will only show you general Pinterest Ads, which have not been created based on the data collected about you.
This collection and transmission of activity data within the scope of the Pinterest Tag is carried out by Pinterest Europe and us as joint controllers within the meaning of Article 26 of the GDPR. Joint controllership exists when multiple parties (joint controllers) work together to decide how data will be used and managed. Joint Controllers need to be clear about who does what to follow data protection rules. They should agree on their roles and make sure the data subjects (people the data is about) understand these roles. Even if they have an agreement, people can still ask each of these parties to respect their data rights. You may see the details of the Joint Controllership Agreement we have with Pinterest below.
We have an agreement with Pinterest Europe concerning this processing as joint controllers. This agreement defines the division between Pinterest Europe and us of the duties under data protection law. In this agreement, we and Pinterest Europe have agreed, among other things, that we are responsible for providing you pursuant to Articles 13 and 14 of the GDPR with all information about our joint processing of your personal data and that Pinterest Europe is responsible for facilitating the exercise of rights of data subjects pursuant to Articles 15 to 20 of the GDPR. You may see more information on this agreement below.
Responsibilities of BSH and Pinterest Europe under the Joint Controllership Agreement
Obligation under GDPR | Pinterest Europe | BSH Hausgeräte GmbH |
Article 6: Requirement of legal basis for Joint Processing | [x] (regarding Pinterest Europe’s processing) | [X] (regarding BSH’s own processing ) |
Articles 13,14: Providing information on Joint Processing of Personal Data | [X] | |
Article 26(2): Making available the essence of this JCA | [X] | |
Articles 15-20: Rights of the Data Subject with regard to the Personal Data stored by Pinterest Europe after the Joint Processing | [X] | |
Article 21: Right to object insofar as the Joint Processing is based on Article 6(1)(f) |
[X] (regarding Pinterest Europe’s processing) |
[X] (regarding BSH’s own processing) |
Article 32: Security of the Joint Processing | [X] (regarding the security of the Ad Data Features) | [X] (regarding the correct technical implementation and configuration of BSH’s use of the Ad Data Feature) |
Articles 33, 34: Personal Data Breaches concerning the Joint Processing | [X] (insofar as a Personal Data Breach concerns Pinterest Europe’s obligations under the Joint Controller Addendum) | [X] (insofar as a Personal Data Breach concerns BSH’s obligations under the Joint Controller Addendum) |
Pinterest Europe is responsible as sole controller for the processing of activity data subsequent to their transmission.
All processing described above, in particular the setting of pixels and cookies for reading out information on the end device used, will only be carried out if you have given us your consent to do so in accordance with Art. 6 (1) point a GPDR. You can revoke your consent at any time with effect for the future by deactivating this service by clicking the Privacy settings icon at the bottom of the screen and changing the settings. Alternatively, you can use the deactivation page for EU consumers at
http://www.aboutads.info/choices or http://www.youronlinechoices.eu/.
You can find more information on how Pinterest Europe processes Personal Data, including the legal basis Pinterest Europe relies on and the ways to exercise Data Subject rights against Pinterest Europe, in Pinterest Europe’s Privacy Policy at policy.pinterest.com/privacy-policy#section-residents-of-the-eea.
In addition, you can find out more about the Pinterest Tag at https://help.pinterest.com/en/business/article/pinterest-tag-parameters-and-cookies.