2. Personal Information We Collect

When we refer to “personal information” in this Privacy Policy, we mean information that relates to an identifiable individual (for example, name, contact details, purchase information). The following types of personal information are collected in connection with our Services:

Information You Provide Directly to us or third parties

Some Services enable us to collect information directly from you or from other companies with whom you have a relationship. For example:

• When you use our Services (for example, when you create a LG Account, register a device or product, make a purchase, review a product or contact us) , you will provide us with information, such as your name, email address, phone number, date of birth, gender, speaker’s voice, photo, video, payment card information, shipping address (including zip code), purchase information and interactions with connected electronic devices.

• When you login with a third party account or profile, we will get access to information, such as, your name and email address and social media tags.

• When you communicate with our customer service staff or other LG Group staff, we will process these communications and other information required to respond to your queries and satisfy your requests.

Information about Your Use of Our Services

In addition to the information you provide, we will collect information about your use of our Services through software on your devices and by other electronic means (such as the use of cookies and sensors). We will collect:

• Device information: Your device name, IMEI, UUID, OS version, country, location, language, IP address mac address, connected modem information, internet router information and settings of devices.

• Log information: Usage information, such as, URL, redirected URL, performance timing, referrer, network type, network info, charge status, ad block info, and cookies. For more information about how we use cookies for our Services, please see Cookie Policy relevant to the Services you are using.

• Location information: We will process your location information based on your consent or where this is necessary to deliver the Service you have requested (for example, by requiring your location information to give you directions).

• Other information about your use of our Services, such as the websites you visit, typing patterns (autofill), connected device behavior and history of use, connected device's power and power usage information and how you interact with content offered through our Services.

We explain below in more detail what types of information we collect when you use our Services:

Other Information We Collect

When we seek your consent, we will explain at the time of obtaining consent from you what information we will be collecting and how we will use it.

Sometimes we receive information about you from third parties including from other companies such as Facebook, Google, Amazon or Line. For example, we may receive your information from third party social networking providers if you choose to connect to our services using your social network account.

We verify certain information you provide with third parties, for example identity verification providers, in order to protect against fraud.

We also use personal information initially collected via LGE’s Smart TV / Media Product service for the purposes described in this Privacy Policy. Please see LGE’s separate Smart Media Product Membership Privacy Policy for further details.

We also collect information about you from other third parties, for example marketing companies and data brokers, in order to better understand your interests and deliver you with more tailored Services and advertising. For example, we receive aggregated information about lifestyle or purchase patterns of certain demographic groups in order to better understand your likely interests.

We may also collect other information about you, your devices, or your use of our Services where required by law (such as where we are mandated by law to collect internet search logs) or with your consent.

Links to Other Websites, Devices, Apps and Features

Our Services may enable you to connect to other websites, devices, apps and other features, which may operate independently from us and have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked website, device, app or other feature is not owned or controlled by us, we are not responsible for its content, use or privacy practices.

3. How We Use this Information

In this section we set out the legal grounds on which we rely to process your personal information and under each legal ground, we explain the purposes for which we collect and use your personal information.

If you use more than one of our services, including Services described in this Privacy Policy and our Smart TV / Media Product service, we will combine the personal information we collect from you in connection with each of those services and use it for the purposes set out below or as described in the privacy policy applicable to the services you use. For example, this prevents you from having to use different logins for different services.

Provision of services based on your contractual relationship with us

We process your personal information when this is necessary under our contract with you, including to:

• Provide you with our services, and specific features you select when using our services, which may require personalising the content of our Services.

• Process orders and payments and deliver to you our products or products of third parties that you purchase through our services and allow you to exercise your warranty rights or other rights you have under your contract. 

• Identify and authenticate you so you may use certain of our services.

Facilitating installations and registrations, resolving technical issues, providing you with customer care support and sending you necessary information relating to the services.

Legitimate interests of the LG Group and/or third parties

We process personal information to the extent this is necessary to fulfil our legitimate interests (or those of third parties), which include our interests to:

• Effectively manage our relationship with our customers, including by communicating with you and responding to your queries;

• Carry out direct marketing activities (when we are not required by law to obtain your consent), including by sending you marketing communications via email, phone calls, post, text messages, social media channels, or via push notifications through our mobile apps, presenting you with online ads both on our services and on third party websites, creating marketing profiles and personalising the recommendations and marketing content we and others present to you, and running promotions, competitions and prize draws. You have the right to object at any time to the use of your data for direct marketing – please see the “Your Choices” section below.

• Protect our business operations against, identify and prevent fraud and other illegal activities or activities prohibited by our Terms of Use.

• Protect the security, availability and integrity of our services and information systems, including by using authentication mechanisms and other security measures, monitoring our systems for security threats, keeping back-ups, anonymising data, and carrying out system maintenance services. 

• Protect our legal rights and the safety of end users, including by handling complaints, obtaining legal advice and establishing, exercising or defending legal claims relating to us or other companies in our group and our Services;

• Improve your user experience, including by providing you with tailored functions, such as an autofill function, a quick search function based on your most visited webpages and additional contents tailored to your interests;

• Improve our services and customer care, including by seeking your feedback and carrying out surveys and market research, performing data analytics on the usage of our services, analyzing customer behaviours, building up customer usage patterns and profiles in order to identify regional and global user trends and optimize our offering to customers globally;

• Effectively manage our business, including by generating reports and analysing the performance of our services (through the use of aggregated information), auditing our business processes, using statistics to make informed business decisions.

Where we rely on our legitimate interests, we have carried out a balancing test to consider what the impact of the processing will be on individuals and to determine whether individuals‘ interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of this Privacy Policy.

Your consent

We seek your consent to process your personal information, where we consider it appropriate or where this is required by law. We use consent to:

• Place cookies and use similar technologies in accordance with our Cookie Policies and the information provided to you when those technologies are used. For more information, see the Cookie Policy relevant to the service you are using.

• Send you marketing communications (where this is required by law or where we otherwise elect to rely on consent).

• Provide you with recommendations and customized advertisements of content, products and services that we or others think you would like, by analyzing information relating to your use of the Services combined with various information that you provide to us by other means, for the purposes consistent with this Privacy Policy and Cookie Policy. This may involve delivering marketing via various channels including through, email, through the LG account, on our websites or on third party platforms (including social networks).

As indicated in this Privacy Policy, your local LG entity and LGEDG act as joint controllers of the processing with respect to this purpose described above. This joint responsibility is due to the fact that, although LGEDG does not have access to your data, it participates in determining the purposes and means of processing for the preparation of profiles.
The above relationship between your local LG entity and LGEDG (joint responsibility) is regulated in accordance with the applicable regulations in a joint controllers agreement. For information on the essential aspects of this agreement, please contact your local LG entity, please refer to the ‘Contact Us’ section below.

On other occasions where we ask you for consent, we will use the data for the purpose explained to you at that time.

When we rely on your consent, you always have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing we carried out before you withdrew your consent. To exercise this right, please see the “Your Rights” section below.

Legal obligations

We process personal information to the extent this is necessary to:

• Comply with our legal requirements under applicable laws (e.g. tax and accounting obligations, obligations relating to product safety, warranties and consumer protection).

• Comply with court orders and subpoenas, and respond to legally binding requests from government, law enforcement agencies, public authorities and/or regulators.

Where we need your information to perform our contract with you or to comply with our legal obligations, you are required to provide this information to us. In other instances, you are not required to provide personal information, however, not doing so may impact the way you use our Services.

4. Sharing Information

We transfer, disclose or otherwise make available personal information about you to third parties as described below:

• The LG Group and personnel: We share personal information between LG Group members and with our personnel, including contractors and agents, and other companies in our group, to the extent this is necessary or reasonable to provide our services and to fulfil the purposes set out in section 3 above or described in the privacy policies relating to our other services. For example, we share your personal information with LGE for product development and improvement purposes, and with your local LG Group member for marketing purposes.

• Service Providers. We transfer or disclose your information to carefully selected companies and individuals that provide services to us; for example companies that help us develop and operate systems for our Services, providers of IT services, security, hosting, Website maintenance, data maintenance and analytics, customer care and communication, order processing and fulfilment, mailing, billing, marketing and market research services, authorised service and repair centres, other administrative services, and companies that run contests, sweepstakes and other promotions on our behalf. These entities are only authorised to access and use your personal information to the extent this is necessary for them to provide us with their services and they are under contractual obligations with the aim of, amongst other things, preventing them from using your information for other purposes. Some of our service providers are located in the Republic of Korea or in other countries outside Europe.

• Third party IoT providers: when you activate third party connectivity features, for example when you connect home IoT devices to our Services, we will share personal information with the providers of those IoT devices to enable you to use the relevant features in our Services.

• Authorised resellers. In certain countries, products on our Website are sold by our authorised resellers. When you purchase products from our Website in these countries, we will share your personal information with these resellers.

• Advertising partners. We share personal information including how you interact with our Services, the ads you see and the purchases you make with social networks and other advertising partners in order to measure the effectiveness of our advertising, improve our marketing practices and help us deliver more relevant advertising to you. In accordance with your marketing preferences, we may also share your personal data with third parties who are offering products or services that we believe may be of interest to you or who are otherwise conducting marketing research and analysis. These parties may use your personal information to contact you with offers or advertisements.

• Other business partners. We will disclose your personal information to other business partners where necessary in order to enable you to access Services you have requested through our Services or promotional materials related to our Services.

• Visitors to our Website. The messages you post to some areas of the Website, including product review boards, chat rooms, forums or other public posting areas can be viewed by other visitors to our Website. [We make clear on our Website where information you post will be visible to others.]

• Business advisors: for example, our lawyers, accountants, business consultants, insurers, auditors, to the extent it is necessary for them to provide us with their services.

• Government authorities, judicial authorities, regulators or other third parties where required: We will disclose personal information to government authorities, judicial authorities, regulators or other third parties where we have a legal requirement to do so or where we believe this is necessary:

- to comply with the law or respond to compulsory legal processes (such as a search warrant, subpoena or court order);

- to verify or enforce compliance with the terms and policies governing our Services and to investigate and prevent fraud or other unlawful activity relating to the use of our Services or affecting our business, to the extent such disclosure is permitted by applicable data protection laws; and

- to protect and defend our rights, property, and the security or safety of our business operations and those of any of our respective affiliates, staff, business partners, our customers or members of the public.

• Corporate Transactions. We may disclose your information to a third party (and their business advisors) as part of a merger or transfer, reorganisation, acquisition or sale (including in the context of negotiations), dissolution or other corporate transaction, or in the event of a bankruptcy.

• Other Parties with Your Consent or on Your Request. In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you separately consent to or request such sharing.

• Analytics We may collect personal information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We may use third-party analytics services, such as Google Analytics, Firebase and others (see more).  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 Services. For example, to learn more about Google Analytics, please visit “How Google uses data when you use our partners' sites or apps,” (located at https://www.google.com/policies/privacy/partners/), “Safeguarding your Data” (located at https://support.google.com/analytics/answer/6004245#zippy=) and “Google Analytics Opt-out Browser Add-on” (located at https://tools.google.com/dlpage/gaoptout).

5. Retention of Personal Information

We take appropriate steps to ensure that we process and retain information in accordance with the following principles:

• at least for the duration for which the information is used to provide you with our Services;

• as required under law, a contract, or with regard to our statutory obligations (e.g., tax laws);

• for as long as it is reasonably necessary to do so to manage an actual or apprehended complaint, investigation or legal dispute;

• only for as long as it is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or, in anonymized form, for statistical purposes, subject to appropriate safeguards. For example, if a dispute arises between you and the LG Group or you fail to make payment for our Services, we may retain relevant information until such dispute is resolved or until such payment is made, respectively. If you delete your entire LG Account, your information will be retained for three months and immediately destroyed thereafter, unless otherwise required under applicable law.

• Where we process your information, 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 indefinitely so that we can respect your request in future.

6. Your Choices

Where permitted we may contact you via email, phone call, text messages or push notifications through our mobile apps. To submit a request concerning the receipt of such communications from us, please contact us using the information specified in the “Contact Us” section below.

You can unsubscribe from our marketing communications at any time by clicking the “unsubscribe” link included at the bottom of emails or by contacting us directly (see “Contact Us” section below). As noted in the Your Rights section below, you have the right to object to use of personal data for direct marketing purposes at any time.

Please note that if you unsubscribe from our marketing communications, we will process your unsubscription as soon as possible, but please be aware that in some circumstances you may continue to receive marketing messages for a short time whilst we process your request. We will also continue to send you service messages to provide you with necessary information in relation to your contract and the Services you use (for example, to update you on changes to our Terms of Use).

7. Your Rights

To the extent provided by applicable law, you can ask your local LG Group member for a copy of the personal information we hold about you. You can also ask us to delete personal information or correct any inaccuracies, to restrict or limit the processing of your personal information, to withdraw your consent and to provide you with personal information that you provided to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, to the extent provided by applicable law, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). You have the right to object at any time to the use of your personal information for direct marketing purposes, including profiling relating to direct marketing.

However, 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 included in both the GDPR and in national laws. We will inform you of relevant exemptions we rely upon when responding to any request you make. To make a request concerning your rights or to make an inquiry, use the contact details under the “Contact Us” section below. In some cases you can also exercise your rights directly through the Website.

8. How We Protect Personal Information

We take the protection of your information seriously and we have in place safeguards designed to protect the information we collect through our Services. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.

9. International Transfer of Information

Your use of our Services will involve the transfer, storage, and processing of your personal information within and outside of your country of residence, consistent with this Privacy Policy. In particular, your personal information will be transferred to the Republic of Korea. Please note that data protection laws and other laws of countries to which your information may be transferred might not be as comprehensive as those in your country.

[For European Residents]

If you are in the EEA (European Economic Area, that is in the European Union and Iceland, Lichtenstein, Norway), UK or Switzerland, we will transfer your personal information to other countries outside the EEA, UK or Switzerland, including the Republic of Korea and the United States. European Union Law recognises the Republic of Korea as adequately protecting personal information. However, where we transfer your personal information to a jurisdiction which is not considered adequate by applicable law, we will take appropriate measures, in compliance with applicable laws, to ensure that your personal information remains protected. Such measures include for instance the use of model clauses which have been approved by the EU, UK and Switzerland. In some instances, we will rely on your explicit consent, where this is appropriate. To request more information or obtain a copy of the contractual agreements or other safeguards in place, use the contact details set out in the “Contact Us” section below.
 

10. Updates to Our Privacy Policy

We will update this Privacy Policy when we change the way we use your personal information, or when we are required to do so under data protection laws. We will bring to your attention any material changes to our Privacy Policy in an appropriate manner (for example, by posting a notice on the webpages and apps through which we provide our Services and indicate at the top of the notice when it was most recently updated).

11. Contact Us

To exercise your rights, or for further information about how we use your personal information, please contact us.

For requests and enquiries relating to information about you collected via the Website or otherwise by your local LG Group member, please contact your local LG Group member. The name of and contact details for your local LG Group member can be found here.

For requests and enquiries relating to information about you collected via all other Services, please contact LGE at [here] or via post [LG Twin tower, 128 Yeoui—daero, Yeongdeungpo-gu, Seoul, Republic of Korea]. LGE’s contact in the EEA is [dpo-eu@lge.com], LG Electronics Deutschland GmbH, Alfred-Herrhausen-Allee 3-5, 65760 Eschborn. The name of and contact details for your local LG Group member can be found here.

Our Data Protection Officer can be contacted at [dpo-eu@lge.com].

If you are not satisfied with how we use your personal information or believe that this is not in accordance with data protection laws, you have the right to complain to the data protection authority where you live, work or where you believe that an infringement of data protection laws has taken place.

12. Personal Information of Children

Our Services are designed for a general audience and are not directed towards children. In connection with our Services, we do not knowingly collect or maintain personal information from anyone under the age of 18 or knowingly allow such persons to use our Services. Please do not provide us with any personal information relating to persons under the age of 18. If you are under 18, please do not attempt to register for our Services or provide us with any personal information. If we learn that a person under the age of 18 has provided us with any personal information, we will promptly delete such personal information. If you believe that a child under age 18 may have provided us with personal information, please contact us using the information specified in the “Contact Us” section above.

In some jurisdictions we may adopt a stricter age-gating policy. Please read the supplemental information for your jurisdiction at the bottom of this Privacy Policy for further information.

LG Entities

Joint controller of your local LG entity for the purpose of profiling

Services