Last Updated: 09 / 30 / 2022
1. Who is responsible for your Personal Information?
Your local LG entity is responsible for operating the Website or other LG Group websites in your country, and for information about you collected through the Website. Your local LG entity is also responsible for any personal information you provide to it directly, for example during customer service calls or product registration cards. LGE is responsible for operating all other Services, and for information about you collected through or in connection with those Services.
The name and contact details of your local LG entity and LGE can be found in the ‘Contact Us’ section below.
2. Personal Information We Collect
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 create a LG Account and register for or use our Services, you will provide us with information, such as your name, email address, phone number, date of birth, account information, including your LG account profile, user ID, password, Home ID, speaker’s voice, photo, video, payment card information, 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
• Device information: Your device name, IMEI, OS version, country, location, language, IP address, mobile ad identifier and settings of devices.
• Product information: model name, manufacturer number, date and location of purchase, photo of receipt
• 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) and how you interact with content offered through 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 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
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.
• 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.
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:
• Send you marketing communications (where this is required by law or where we otherwise elect to rely on consent).
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.
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.
• Google Analytics / FireBase 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 and Firebase. 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. 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 Informaition
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); or
• 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 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 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).
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).
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
[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.
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]. The name of and contact details for your local LG Group member can be found here.
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 14 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 14. If you are under 14, 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 14 has provided us with any personal information, we will promptly delete such personal information. If you believe that a child under age 14 may have provided us with personal information, please contact us using the information specified in the “Contact Us” section above.
LG Electronics Singapore Pte. Ltd.
LG Electronics Inc.
LG Twin tower, 128 Yeoui—daero, Yeongdeungpo-gu, Seoul, Republic of Korea
LG Electronics Inc.
LG Twin tower, 128 Yeoui—daero, Yeongdeungpo-gu, Seoul, Republic of Korea
LG Electronics Singapore Pte. Ltd.
Last Updated: 04 / 26 / 2022
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