Privacy Policy

 

GENERAL

Respecting and protecting our customers’ privacy and personal data is important to Techtronic Industries Company Limited and its related companies (including all subsidiary and affiliate companies) (collectively, we or us). This Privacy Policy will help you understand how we collect, use and safeguard your personal data in our interactions with you.

It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the section. What rights do I have?

 

WHAT INFORMATION DO WE COLLECT?

We collect and process personal data about you when you:

  • visit and/or register on any websites owned and operated by us (including www.milwaukeetool.eu, uk.milwaukeetool.eu, www.milwaukeetool.com, https://uk.ryobitools.eu/ and www.milwaukeetool.asia) (collectively, our Site)
  • use a third-party service offered by service providers such as analytics companies, advertising networks and cooperatives, demographic companies, and any other third-party service providers that we choose to collaborate or work with, and we obtain your personal data from those third parties;
  • provide us with your personal data via: Wi-Fi, mobile devices, social media platforms/networks or telephone enquiries, your application for or use of our services;

In this Privacy Policy, your personal data means: your name, email address, contact number, MAC address, IP address, credit/debit card and other payment information, gender, date of birth, age, interests, geographical location, Site usage (including browsing behaviour / activities), shopping and purchasing behavior, and other personal data you provide.

 

HOW DO WE USE THIS INFORMATION, AND WHAT IS THE LEGAL BASIS FOR THIS USE?

We process personal data for the following purposes:

To conduct our business and pursue legitimate interests, in particular:

  • To provide our services to you, including responding to any questions you may have, providing you with recommendations on our products or services, providing you with information about the Company;
  • We monitor use of our Site and our services, and use your information to help us monitor, improve and protect our products, contents, services and websites;
  • To process your registration for any investor-related, marketing and promotional information, activities or events;
  • To process your registration as a registered user of our Site;
  • To provide you with regular communications from us with details of our products, services and relevant benefits and information;
  • For investigation of complaints and suspicious transactions;
  • For prevention or detection of crimes;

When you give us consent (if required):

To provide you with direct marketing communications in relation to products, services, events, offers or promotions, provided by: (a) us or our related companies (including our affiliate and subsidiary companies), (b) business partners, and (c) other third-party providers. Such marketing communications may be in various forms, including advertisements, special events notifications, newsletters or announcements, and delivered via various methods in accordance with the personal data that you provide to us, such as by email, SMS, WeChat/Whatsapp. messages, smartphone app. push notifications, notifications on your social media pages, in–app messaging or postal mail.

Such marketing communications may market or offer any kind of products, services or information which we think may be relevant to you based on information you provide to us (for instance, via your participation in our surveys).

For purposes which are required by law:

In response to requests by government or law enforcement authorities conducting an investigation.

 

RELYING ON OUR LEGITIMATE INTERESTS

We have carried out an assessment on all the data processing activities described above in order to weigh up any privacy implications against our legitimate business interests. You can obtain information on any of our assessments by contacting us using the details set out later in this policy.

 

WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO DIRECT MARKETING

Wherever we require your consent under applicable law, you will always be able to withdraw any consent provided to us. We shall cease to use your personal data for the purpose in respect of which you have withdrawn your consent, but we may still use, process, store and transfer your data for other purposes, such as those set out above. Specifically, in the case of customers or investors from the European Economic Area (EEA), we are able to send you direct marketing without your consent, where we rely on our business or legitimate interests. Irrespective of the legal basis on which we rely to send you direct marketing, you have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by: (a) contacting our Privacy Officer at privacyoffice@tti.com.hk or sending your request by post to: Privacy Officer, Techtronic Industries Company Limited, 29/F, Kowloon Commercial Centre, 51 Kwai Cheong Road, Kwai Chung, Hong Kong SAR., or (b) in the case of direct marketing emails, by clicking the unsubscribe link at the bottom of such emails.

 

WHO WILL WE SHARE THIS DATA WITH, WHERE AND WHEN?

We may share your personal data with the related companies of Techtronic Industries Company Limited located within or outside Hong Kong SAR. for the purposes set out in How do we use this information, and what is the legal basis for this use? section above.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes set out in How do we use this information, and what is the legal basis for this use? section above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

Personal data will also be shared with third party service providers located within or outside of Hong Kong SAR., who will process it on our behalf for the purposes identified in this Privacy Policy. In particular, we use the following third-party providers:

  • Courier services;
  • E-mail/SMS/MMS/WeChat blasting services;
  • Telecom companies (for providing in-store Wi-Fi services);
  • Data storage and cloud service providers (for storage of your personal data and hosting of applications that process your personal data for the purposes identified in this policy);
  • Google, Facebook, Rakuten Marketing and other advertising networks (for matching of your personal data with their database in order to send you our direct marketing materials through your Google and/or Facebook account(s));
  • Marketing (including digital marketing) and website analytic agencies (for display of advertising materials on our Site and other websites that you may visit, and analysis of your online behaviour and usage of our Site – these agencies use cookies; please refer to our separate Cookies Policy for details); and
  • Data analytics and hackathon service providers and agencies (for the purposes stated in Clause How do we use this information, and what is the legal basis for this use? section above, in which only anonymized data will be sent to service providers for those purposes in How do we use this information, and what is the legal basis for this use? section above)

In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

If you are located in the EEA, where information is transferred outside the EEA, and where this is to a business partner or third party service provider in a country that is not subject to an adequacy decision by the EU Commission, data will be adequately protected by EU Commission approved standard contractual clauses, or third party or business partner’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to the contact mentioned in the section How do I get in touch with you below. Your personal data may be transferred to Hong Kong and Macao Special Administrative Regions, Mainland China, Taiwan Region, Indonesia, Singapore, Malaysia, Philippines, Australia, New Zealand, United States, Japan, South Korea, Vietnam and Thailand.

 

WHAT RIGHTS DO I HAVE?

Where permitted by law, you have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, if you are located in the EEA, you can object to the processing of your personal data in some circumstances (in particular, where we do not have to process the data for business or other legitimate interests, purposes for which consent has been given (including direct marketing) or other legal requirements).

These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are available under applicable laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interest assessment, you can get in touch with us – or our privacy officer – using the details set out below. (Applicable only if you are located in EEA: If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.)

 

HOW DO I GET IN TOUCH WITH YOU

If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at privacyofficer@tti.com.hk or by writing to Privacy Officer, Techtronic Industries Company Limited, 29/F, Kowloon Commercial Centre, 51 Kwai Cheong Road, Kwai Chung, Hong Kong SAR. You may also access, verify or update your personal data by logging into the Site or completing the “Customer Information Renewal Form” which will be provided to you upon request.

 

WHO IS THE DATA CONTROLLER?

The data controllers are Techtronic Industries Company Limited, and its related companies; contact details can be found in the section How do I get in touch with you? above.

 

HOW LONG WILL MY DATA BE KEPT?

Where we process registration data, we do this for as long as you are an active user of our Site and it is required for business and legitimate interests or legal requirement.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in the future.

(Applicable if you are located in EEA only) Where we process personal data for site security purposes, we retain it for 7 years after any business and legitimate interests no longer exists, and where we process personal data in connection with performing a contract or for a competition, we keep the data for 7 years from your last interaction with us.

 

CALIFORNIA CONSUMER PRIVACY ACT

Notice for California Residents

This notice applies solely to all visitors who reside in the State of California and is presented in compliance with the California Consumer Privacy Act of 2018 (“CCPA”).

Information we collect

We are required to disclose to you the categories and sources of personal data we collect within the last 12 months. Please refer to the sections What information do we Collect? and How do we use this information, and what is the legal basis for this use? for details on the personal data we collect.

Sharing personal data/Do not sell my personal data

We may disclose your personal data to third parties for a variety of business purposes. Please refer to the Who will we share this data with, where and when? section for details.

We do not sell your personal data to third parties for their own marketing and advertising or other business purposes.

Your Other California Privacy Rights

Right to Know

You have the right to request us to disclose to you certain information about our collection of your personal data over the past 12 months. Upon receipt and confirmation of your verifiable customer request, we will disclose to you:

  • The categories of Personal Information we collected about you
  • The categories of sources from which we collected Personal Information about you
  • Our business or commercial purpose for collecting or selling such Personal Information
  • The categories of third parties with whom we share such Personal Information
  • The specific pieces of Personal Information we collected about you

Right to Request Deletion

You have the right to request us to delete Personal Information we collected from you. Upon receipt and confirmation of your verifiable customer request, we will delete such Personal Information from our records, unless it is necessary for us or our service providers to:

  • Complete the transaction for which such Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with applicable law, provide a good or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely render impossible or seriously impair the achievement of such research, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; or
  • Use such Personal Data, internally, in a lawful manner that is compatible with the context in which you provided such Personal Information.

Right to access Personal Data

You may submit requests to exercise your rights in relation to your personal data to the email address set out in the How do I get in touch with you? section. We will seek to disclose and deliver to you the required information in accordance with the CCPA.

Right not to be discriminated against

We will not discriminate against you because you exercise your California privacy rights, and will not deny you goods or services, charge you a different price or rates for goods or services, or provide a lower quality of goods or services to you due to the exercise of such rights.

Last updated: 18th February, 2021