LG Hausys Europe GmbH General Privacy Policy

LG Hausys Europe GmbH (“LG Hausys Europe” or “Company”), a Germany subsidiary of LG Hausys, Ltd. (“LG Hausys”) in South Korea, collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (‘GDPR’) which applies across the European Union (including in the United Kingdom) and we are responsible as controller of that personal information for the purposes of those laws.

LG Hausys is in business of manufacturing, buying, selling and servicing of certain goods and services and LG Hausys Europe is a sales subsidiary for some of the goods and services for Europe. LG Hausys Europe currently services for Solid Surface Materials (aka HI-MACS), Automotive and Deco Films. In response to the relevant laws and regulations and foremost, by furtherance of good business ethics, LG Hausys Europe is committed to safely protect your personal data given to us and we promise that we will only use your personal data for the purpose(s) provided by you to the Company.

LG Hausys Europe collects and processes minimally required personal data to observe furtherance of its commercial interest only. Thereon, LG Hausys Europe will process all personal data only for the purpose specifically given or otherwise permitted by law. All personal data entrusted with LG Hausys Europe will forever remain confidential to unrelated third parties.

What is personal data?

‘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.  [GDPR Clause 1, Article 4]

HIMACS.EU (the “Website”)

Type of Requests Available on the Website (‘Contact Us’):

*To provide customers with excellent services, the Company may share certain customer information with its contracted distributor and other business partners. Rest assured, the Company has its internal policy to process all personal data for the specific purpose provided or permitted by law. For certain business cases or requests, the Company’s Country Manager or Project Manager will make reasonable business decisions to transfer relevant personal information to the distributors and other business partners for the furtherance of commercial objectives. To adequately comply with your request, the Company may ask you for more information as it becomes necessary.

• GENERAL: Questions relating HI-MACS products and/or services and there is no required format for this request. The Company will do its best to comply with your reasonable commercial requests to further the common interest.
• CONTACT YOUR DISTRIBUTOR: The Company will share your information and input with a distributor in your area, and if you choose to provide us with optional information, such as your phone number, such information will be used to expeditiously process your request.
• ASK FOR SAMPLE: A particular sample of the Company’s product is being requested. In order to adequately process your request, the Company requires relevant information, such as your name (last and first) and address. Based on availability or capacity, your request may be fulfilled by a distributor or LG Hausys in Korea. A representative of the Company or its distributor may contact you to verify the information provided herein.
• ASK US TO PASS A TEST:  If you are in need of a particular certification or testing related to the Company’s products and services, you are recommended to leave your contact information for expeditious processing.
• ASK FOR AN EXPERT VISIT: If you want to request a visit by a person with product and service knowledge, then the Company will comply with your request by sending a representative of the Company or an employee of the Company’s distributor or other business partner. In order to facilitate to your request, the Company will require your contact information, inclusive of an address.
• BECOME A HI-MACS FABRICATOR/INSTALLER NOW: If you are interested in becoming a certified HI-MACS fabricator/installer or would like to make an inquire thereof, please input your information into applicable boxes. Providing additional contact information, such as your phone number, will allow us to expeditiously process your request.
• HI-MACS WARRANTY: You can make an inquiry relating to a product warranty and ask for other relevant information.

Providing Newsletter to Subscribers (‘Request for Newsletter’)

• LG Hausys Europe provides Newsletter services only to those voluntarily and explicitly subscribed thereto.
• Periodic E-Mail newsletter is serviced by MailChimp in the U.S.

SALESFORCE.COM (the “CRM”)

*The Salesforce.com is a U.S.-based CRM (Customer Relationship Management) system used by the Company. All personal data collected via himacs.eu or ordinary course of business for HI-MACS will be either automatically uploaded by means of automatic connection between the databases (himacs.eu and Salesforce) or direct input by an authorized personnel.

DIRECT SALES

*Direct Sales refer to any and all traditional and ordinary course of business taken off-line. However, some referral may be made directly by a source using E-Mail system. Any and all referrals and traditional business method, such as exchanging of business cards, phone calls, on-the-ground business transactions, exhibitions and trade shows, etc. will be considered as Direct Sales.

• For the furtherance of commercial interest, the Company will process all personal information received from Direct Sales into the CRM. However, such personal data, unless specific purpose or appropriate consent is documents, will be only used when and if the Company receives consent or specific instruction from the respective data subject. Such method will be carried out by the aforementioned “Thank You” or confirmatory E-Mail.
• Absent appropriate consent or specific purpose provided, the Company shall delete all personal information collected from the database within 30 days of the initial input into the CRM.

THE NEWSLETTER SERVICES / THE MEDIA ALERTS

• The Newsletter Services are offered to you at no-cost  for informational purposes and may be unsubscribed at any time.
• The Company sends out Newsletters using the E-Mail service provider, MailChimp. To enable such services, your email information and the language you choose will be provided to MailChimp and the CRM.
• You are free to unsubscribe from the Newsletter services at any time for any reason by clicking the “Unsubscribe” link provided in all Newsletters or by contacting the Company via E-Mail or by calling (49)-69-583-029 469.
• The Media Alerts are offered to you at no-cost for press-related purposes and may be unsubscribed at any time.
• You are free to unsubscribe from the Media Alerts at any time for any reason by making such withdrawal request to the E-Mail address of Mariana Fredes (mfredes@lghausys.com) or by calling (49)-69-583-029 469.
• The Company sends out the Media Alerts using the E-Mail service provider, MailChimp. To enable such services, your email information, name, and other information you input will be provided to MailChimp and the CRM.

GENERAL APPLICABILITY

The Company collects and processes your personal data by using one or more of the lawful bases permitted under the laws and regulations (such as performance of contract, legitimate interest of the Company, required by law, etc.).

• If the data subject does not provide the Company with sufficient personal data to perform for a data subject’s request, then the Company will not be able to proceed.
• If you made consent to specific use, then you are free to withdraw your consent at any time. Please refer to https://himacs.eu/en/rights-data-subject  for more details on withdrawal, unless specified otherwise hereunder.
• The Company does not collect or process personal data of a minor child. The Company sets, as its internal policy, the age of consent to be 18. However, if the minor has legitimate interest in doing business with the Company and permitted by laws and regulations (such as obtaining authorization from legal guardian or parent), he or she may able to submit certain personal information for the furtherance of mutual commercial interest. There is no other exception.
• The Company currently does not implement any features or services related to automated decision making or profiling.
• The Company, unless required by law, does not collect or process any specially categorized personal data as set forth in by the GDPR.

2. Personal Data Retention Policy

The Company conforms to the data retention period as permitted or required by law. However, if it is not clearly specified or managed by law, then the Company shall reasonably set the retention period as its internal policy. When and if the data subject makes a request for deletion of certain or all of his or her personal data, then the Company will do so without undue delay unless other reasonable ground exists.

Please refer to the Company Personal Data Retention Policy for further details. As a general standard, LG Hausys Europe does not retain personal data for longer than the period necessary. As a general rule, the 3-year mark is considered as the point of deletion for unused personal data, absent other reasonable ground exists to further retain. In short, if LG Hausys Europe does not use your personal data for 3 years, then it will be deleted automatically.

For statistical purpose in the interest of commercial objectives, the Company may safely archive expired or terminated personal data by anonymizing (no one will be able to identify who it is) such data.

The Website

• All personal data collected from the Website is automatically transferred to the CRM. Once the transfer is successfully completed, the respective information will be deleted from the databases of the Website within one week, unless an error arose and the respective transfer was not made.
• Absent request made under appropriate rights of the data subject (various ‘Rights of the Data Subject’ afforded under the GDPR), all personal data collected via ‘Contact Us’ shall be maintained until unused for 3 years. In short, any personal data unused for 3 years from its last modification, access, or use date, will be deleted. However, the Company may retain any personal data when it has overriding legitimate interest or permitted otherwise by law.
• When you subscribe to the Newsletter services via ‘Contact Us’ page, your data provided therein will be excepted from the deletion. If you unsubscribe from the Newsletter services, such service will immediately stop. Thereon, your remaining personal data obtained from the ‘Contact Us’ will be deleted in accordance with the Company internal policy as stated above, absent separate request made by you to immediately delete.
• Absent request made under appropriate rights of the data subject, all personal data collected via ‘Request for Newsletter’ shall be maintained until unsubscribed. If you unsubscribe from the Newsletter services, such service will immediately stop.  Thereon, applicable personal data will be deleted within 30 days of the un-subscription request.
• If a data subject requests regular mailing service via Newsletter Menu, respective personal data will be excepted from the data targeted for deletion even after three days. If the data subject withdraws from consent or makes a request to delete, all respective personal data will be deleted within 30 days or 60 days as deem permissible.
• All personal data collected and processed in relation solely to the Partner’s page will be promptly deleted upon termination, cease, or expiration of commercial or other types of business relationship. Absent other reasonable grounds, period for deletion shall not exceed 30 days from the last day of such relationship.

The Newsletter Services / The Media Alerts

• When you subscribe to the Newsletter services via ‘Contact Us’ page or by other means in combination of your other commercial request, your data provided therein will be excepted from the deletion. If you unsubscribe from the Newsletter service, such service will immediately stop. Thereon, your remaining personal data obtained from the ‘Contact Us’ will be deleted in accordance with the Company internal policy as stated above, absent separate request made by you to immediately delete.
• If you only subscribed to the Newsletter services (using the Newsletter tab and not through ‘Contact Us’) and you choose to unsubscribe, the Newsletter service will immediately stop and your personal data provided therein will be all deleted within 30 days.
• If you made a request to only receive applicable Media Alerts (using the ‘Newsroom’ in the Website or via direct request to the Company’s marketing manager) and you choose to no longer receive such alerts, the Media Alerts will immediately stop and your personal data provided therein will be all deleted within 30 days.
• For the avoidance of doubt, if you made other type of request, then your duplicate personal information may be excepted for the purpose provided therein.

The CRM

• Unless specified herein or subject to request made by applicable data subject, all personal data collected and processed in relation to the business partners (inquirers, requestors, distributors, fabricators, etc.) will be deleted in accordance with the Company’s internal policy (generally three years after unused or longer as deemed necessary).
• For the personal data of point-of-contact, signatory, or person-in-charge relating to a commercial or other types of similar contractual relationship thereof shall be stored for 10 years, upon termination, expiration, or cancellation of such contractual relationship.
• Absent request made under appropriate rights of the data subject, all personal data collected for the use of Newsletters services (input of data by the Company’s employees after direct sales) shall be maintained until unsubscribed. If you unsubscribe from the Newsletter services, such service will immediately stop.  Thereon, applicable personal data will be deleted within 30 days of the un-subscription request.

3. Matters Regarding Transfer of Your Personal Data to a Third-Party

The Company, in order to efficiently process and safeguard data, processes or transfers applicable data to its affiliates and external service providers. All personal data provided herein shall only be collected and processed for the purpose provided by you.

For any personal data being collected and processed transferred to a third party or transferred internationally, the Company shall provide all data subject to the Article 6(1)(b), ‘processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a Contract’ and/or the Article (6)(1)(f), ‘processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child’, or otherwise required by law.

• All personal data collected from the Website is connected and processed real-time to Salesforce.com, a CRM (Customer Relationship Management) system that the Company elects to use.
• The management for system operations of the Website is consigned to two external service providers, Royalkomm and Internet X. These service providers, as part of their service related to the Website, will be able to access your personal information collected through the Website.
• As mentioned above, ‘Salesforce.com’ is a CRM system interfaced with the database of the Website and such system is currently being serviced by Salesforce to provide you with excellent services. The Company may share your personal information, only for the purpose provided by you, with a contracted distributor or other adequate business partner located near you to further such purpose. For certain request, the involvement of a contract distributor is necessary.
• For requests or matters that cannot be handled solely by the Company may be provided to LG Hausys, Ltd. in Korea (LG Hausys HQ) for additional assistance. Such request will only be transferred to fulfill the purpose provided by you.
• The Company uses an internal E-Mailing e.com Inc. This service provider, as part of its service related to the CRM, will be able to access your personal information collected through the Website.
• The Company Newsletter services are being serviced by MailChimp. This service provider, as part of its service related to the Newsletter services, will be able to access your personal information collected through the Website.
• To better provide system provided by LG Hausys, Ltd. and its service provider for such system is LG CNS. This service provider, as part of its service related to the internal E-Mailing system, will be able to access your personal information collected.
• When and if the relationship with an aforementioned service provider ends, absent lawful reasons to retain, all personal data processed in the course of the relationship will be deleted by such service provider as soon as the relationship ceases to exist.
• The Company collects and processes your personal data by using one or more of the lawful bases permitted under the laws and regulations (such as performance of contract, legitimate interest of the Company, required by law, etc.). If you do not provide the Company with sufficient personal data to perform for your request, then the Company will not be able to proceed to fulfill your request.
• If you do not feel comfortable using the website or by other online method (i.e. E-Mail) to submit your personal data, then you may choose to reach out to the Company by making a phone call to the Company’s main phone number. However, for certain requests,  the third-party transfer is unavoidable.

5. Matters Regarding Automated Decision-Making, Profiling

The Company currently does not implement any type of automated decision-making such as profiling or others having similar or substantial effects on a data subject.  If changes occur, this General Privacy Policy shall be revised accordingly to notify the users of its details.

6. Complying with Request Relating to the Rights of the Data Subject under the Privacy/Data Protection Laws and Regulations.

In accordance with the rights provided by the GDPR and other relevant laws and regulations, you can request the following from the Company:

1. To Access Personal Data relating to You (‘Access to Personal Data’)
2. To Modify/Rectify Personal Data relating to You (‘Rectification of Personal Data’)
3. To Delete Personal Data relating to You in its Entirety or Partially (‘Deletion of Personal Data’)
4. To Limit Certain Processing  of Your Personal Data (‘Limitations of the Processing of Personal Data’)
5. To Request Data Porting of Your Personal Data (‘Personal Data Portability’)
6. To Object on Certain Processing of Your Personal Data (i.e. profiling) (‘Objection to the Processing of Personal Data’)
7. To Inquire into the Automated Decision-Making relating to Your Personal Data (‘Automated Decision Making’)
8. To Withdraw from Certain Consent Made to Process Your Personal Data (‘Withdrawal of Consent to Personal Data’)

The above form is only effective only when and if the Company has any personal data relating to you. The Company may refuse to comply with your request when there is necessity to process your personal data for certain lawful purpose (contract, required by law, etc.) or the Company has overriding legitimate interest to process.

If you want to make a request as mentioned above, you can download the respective form from https://himacs.eu/en/rights-data-subject and submit such request to the gdprweb@lghausys.com. In order for us to process your request, you must fill-in all required information and thereon, you are strongly encouraged to fill-in additional information reasonably related to your request.

For all requests, the Company is to use only the contact information already within the CRM or in other applicable databases. As the Company mandatorily require an E-Mail address for all commercial requests, such E-Mail address will be the primary contact information to be used. If there is an additional contact information available, such as phone or address, then such method may be used to verify the identity of the requestor. When a different E-Mail address against what the Company has is used, then the Company will ask for verification of the requestor’s identification.

In case of any request received from a proxy, the Company will only process such request when the identity of the proxy is verified (photo ID, etc.) and lawful power of attorney is received.

The standard processing time permitted by law is to respond within 30 days of the request. If the Company cannot process such request within the permitted time period, then you will be notified with the reasons for the delay and the anticipated delivery date. When there is an abusive, excessive, and/or repetitive request made, the Company may charge reasonable administrative fees to process such request. 

7. Matters Regarding Technical Protection Measures

The Company devises the following technical protection measures to implement safeguard so that personal data does not get lost, stolen, leaked, falsified or damaged when processing your personal data.

1. Measures against hacking, etc.

    : The Company runs a vaccine program to prevent its PCs that are processing your personal data from being infected with a virus and the Company periodically improve weakness in systems by conducting penetration testing where applicable. Furthermore, security devices (SSL, etc.) are operated to transmit personal data safely on the network used by the Company.

2. Storage of access records

    : The Company secures traceability by storing and managing records (web logs, summarized information, etc.) of access to the personal data processing system. There is no active monitoring of such records and such records will used when there is an issue or to take preventative measures.

3. Restrictions on access to personal data

    : The Company actively manages the permission of each access group, whether of its employees or of its business partners, to sufficiently implement reasonable measures against data protection. Such action may include, granting, changing, and terminating one’s access. The Company only permits a small number of authorized employees to such management roles. Any and all creation, deletion and changes related to access will be recorded in accordance with the Company’s internal policy.

4. Deletion of personal data

    : The Company regularly deletes personal data, whose purpose of use is expired, from applicable databases.

The above protection measures do not guarantee perfect security. However, the Company will act diligently to prevent further damage, when there is actual or suspicion of personal data breach.

8. Matters Regarding Cookies

The Company operates “cookies” that store and retrieve your personal data frequently to provide you with a more comfortable homepage environment.

  - What are cookies?

    : Cookies are very small test files that the server which is used to operate a homepage sends to your browser. They are sometimes stored in your computer’s hard disk.

 - Purposes of using cookies.

    : To provide a faster web environment to you by storing your preferred settings, etc. To improve services.

 - Setting of cookies

    : You can choose whether to install cookies or not. Therefore, you can allow all cookies, go through confirmation whenever cookies are stored, or reject storage of any cookies by setting the option on your web browser.

 - Google Analytics

   : This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”).  Google Analytics uses “cookies,” which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States . Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services      relating to website activity and Internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.  You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of this website.  By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Please see the following for more details on how to check, manage and delete cookies set on your computer. http://www.allaboutcookies.org

9. In Charge of Data Protection

■ LG Hausys Europe GmbH

     - Address:  Lyoner Street 15, 60528, Frankfurt am Main, Germany

     - Phone:   (49)-69-583-029 469

     - E-Mail:  gdprweb@lghausys.com

■ Department in charge of the data processing and protection for HI-MACS Products/Services and the Website

     - Department Name: LG Hausys Europe GmbH, HI-MACS Team

■ Data Protection Officer of LG Hausys Europe

     - Name:    IBS data protection services and consulting GmbH, Dr. Michael Foth

     - Address: Zirkusweg 1, 20359 Hamburg, Germany

     - Phone:    (49)-(0)40-696-985-24

     - E-Mail:    info@ibs-data-protection.de

■ To lodge a complaint to the supervisory authority in Hessen, Germany.

If you need damage relief or a consult on infringement of personal data, you can contact the following institution:

※ The following institution is a public body and is separate from the Company. If you are not satisfied with the result of the Company’s acts on responding to claims or complaints, or need more specific assistance, please contact the following.

 * Supervisory Authority in Hessen, Germany

    - Name:  Der Hessische Datenschutzbeauftragte

    - Tel:   +49 06 11/140 80

    - Fax:   +49 06 11/14 08-900

    - E-Mail:   poststelle@datenschutz.hessen.de

    - Website:   http://www.datenschutz.hessen.de

This Privacy Policy takes effect on May 25, 2018.